Revenue risk in the battery auction

At Canal Conecta 2026, a video panel by Canal Solar set out a concern about the draft rules for the battery auction: the seller bears the risk of not receiving revenue, even without controlling collection. A legal dispute or a shortfall of funds in the paying account would fall on the investor.

The point was already on the regulator's table. In contributions to ANEEL Public Consultations 22 and 23/2026, reported by Cenário Energia on 21 September 2026, ABSAE asked that the seller be relieved of sole responsibility for receiving the capacity reserve charge. The argument: invoicing, collection, settlement and pass-through are CCEE's responsibility, outside the project's control.

The contracts run for 15 years, with auctions scheduled for December 2026 and supply from August 2028. Risk that the project does not control enters the bid as a premium, and the association warns of the effect on bankability.

The final wording of the tender document decides who absorbs this risk. The clearer the separation between business risk and institutional risk, the smaller the premium built into prices.